Recently, we have become aware of several instances
where dealers who have issued a temporary license plate to a consumer submit
paperwork to a tax collector or license plate agency requesting a title only. Some offices/agencies are processing these transactions while others are
refusing to do so.

Tax collector offices and license plate agencies are
not authorized to process a title only transaction when a dealer has
issued a temporary license plate. If a dealer issued a temporary
license plate to the consumer, the dealer must apply for a permanent license
plate for the consumer at the same time the dealer submits the title application
to the tax collector office or license plate agency.

Dealers should not issue a temporary license plate to
any vehicle for which a title only transaction is requested. Checking the
non-use affidavit on the application, which indicates the vehicle will not
be operated on the streets of this state, while at the same time processing a
temporary license plate so the vehicle can be operated on the streets of
this state, is considered fraud. Dealers who participate in this activity may be
subject to fines, suspension, or revocation of their license.

Section 319.23(7),
F.S., clearly states that the department shall in no event issue a certificate
of title for any motor vehicle or mobile home to any applicant until the
applicant has shown that a current motor vehicle registration as required by s.
320.02,
F.S., has been obtained.

Most dealers understand that they must apply for title
within 30 days of delivery of a vehicle. Some dealers may not be aware,
however, that they must also apply for registration. Under Florida law, the
dealer is required to apply for a registration for the consumer at the same
time the dealer makes application for title. The only exception is if the
vehicle will not be operated on state roads. Then a non-use affidavit is
appropriate.

We remind you to follow procedure RS-31, Temporary
License Plates, which states that tax collectors, dealers, and other agents of
the department may not issue a temporary license plate for use on
a specific motor vehicle if the owner of that vehicle has filed or intends
to file a non-use affidavit as part of an application for certificate of
title. Therefore, if the owner does not
intend to use the vehicle, the dealer should not issue a temporary
license plate.

If
you have questions or need additional information, please contact the Field
Support Center.